Action 13 of the OECD/G20 BEPS project “Guidance on Transfer Pricing Documentation and Country by Country Reporting” can be considered to be one of the key deliverables. The action proposes to enhance transparency for tax administrations and contains revised standards for transfer pricing documentation and consists of three layers of documentation:
This 3rd layer –the Country by Country or “CbC” report provides a challenging set of instruments in the hands of the tax authorities. Although the CbC is not seen as a “information set defining the facts on which taxation takes place”, it does cover:
As a consequence of this detailed information, we expect Multinationals to prepare today for a multitude of queries from tax authorities and possibly other stakeholders. Furthermore, as a response, different “being in control” statements are being launched to the market place to facilitate Multinationals to remain in the “drivers’ seat” on their global transfer pricing risk position.
TPA together with TPH/Pebbleage provides the solution to collect the required CbC data fully automated.
The webinar will address the following topics:
During the webinar we will show you a demonstration on: